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Megan Ruigrok

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Megan is a Dutch lawyer with more than seven years experience with tax dispute resolution, procedural tax law, international tax law, DAC6 (Mandatory Disclosure) and transactional work. She represents clients during all stages of tax disputes, including (cross-border) audits, administrative appeals and litigation and she assists clients with tracking global tax controversies, MAP procedures and legal opinions. Her experience encompasses a broad range of issues, including disputes on: transfer pricing, business restructurings, corporate income tax, information obligations, exchange of information, effective place of management and tax residency/permanent establishments. Megan represents clients from a wide variety of industry sectors before the tax courts in the Netherlands and advises clients in a wide variety of industry sectors on tax matters. Megan spent a year on secondment in our Chicago office with the US Tax Controversy team and has experience with US and international tax controversies. She also advises clients in a wide variety of industry sectors on tax matters and mergers and acquisitions, including but not limited to due diligence, SPA negotiations, W&I policy negotiations and specific Tax Insurance policy negotiations.

On 28 April 2023, the Dutch state secretary of finance published an updated version of the Dutch guidance on the mandatory disclosure regime on cross-border transactions, generally known as DAC 6. The slight amendments to the previous guidance are due to signals from the public and are intended to help tax practitioners and other intermediaries determine what transactions must be reported. In our view, the changes also intend to reduce the number of reported transactions that are clearly outside the scope of DAC 6. Furthermore, the updated version clarifies the Dutch government’s position on legal privilege in light of the 8 December 2022 judgment from the Court of the Justice of the EU.

On 21 November 2020 the European Member States reached consensus on a proposal for the seventh Directive on Administrative Cooperation (“DAC7”). The updated Directive is a part of a package which was published by the European Commission earlier this year to promote fair and simple taxation.1 It is expected that DAC7 will be officially adopted on short notice.

DAC7 introduces an obligation for certain digital platforms to collect and report information to their local tax authority on income generated by certain sellers on those digital platforms. This reporting obligation imposes an additional compliance burden for the digital platform companies in scope, as such companies will be confronted with an additional due diligence and reporting obligation.

This tax alert will provide the most relevant considerations of DAC7. We note that preparations are already in motion for an eighth Directive (“DAC8”) which will cover crypto assets.

Read publication We are pleased to enclose the June issue of Tax News and Developments, a publication of Baker McKenzie’s North America Tax Practice Group. This month’s edition features Proposed Regulations on Deductibility of Certain Fines and Penalties and Related Information Reporting Retirement Relief Provisions Accessible to More Taxpayers and…

Read publication We are pleased to enclose the February issue of Tax News and Developments, a publication of Baker McKenzie’s North America Tax Practice Group. This month’s edition features a discussion on three Tax Court opinions under section 6751 (b), final withholding regulations, a review of final and proposed BEAT…